Ludwig v. IMI Fabi LLC

2025 NY Slip Op 51496(U)
CourtNew York Supreme Court, Niagara County
DecidedSeptember 23, 2025
DocketIndex No. E187366/2025
StatusUnpublished

This text of 2025 NY Slip Op 51496(U) (Ludwig v. IMI Fabi LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, Niagara County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ludwig v. IMI Fabi LLC, 2025 NY Slip Op 51496(U) (N.Y. Super. Ct. 2025).

Opinion

Ludwig v IMI Fabi LLC (2025 NY Slip Op 51496(U)) [*1]

Ludwig v IMI Fabi LLC
2025 NY Slip Op 51496(U)
Decided on September 23, 2025
Supreme Court, Niagara County
Walter, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.


Decided on September 23, 2025
Supreme Court, Niagara County


Craig Ludwig, et al., Plaintiffs,

against

IMI Fabi LLC, et al., Defendants.




Index No. E187366/2025

Shaina Weissman, Esq.
Simon Greenstone Panatier, PC
John P. Comerford, Esq.
Lipsitz &Ponterio & Comerford LLC
Attorneys for Plaintiff

Joseph R. Connelly, III, Esq.
Peter Adolf, Esq.
Womble Bond Dickinson (US) LLP
Attorneys for Defendant
IMI Fabi LLC Raymond W. Walter, J.

This matter comes before the Court on Defendant IMI Fabi LLC's ("Fabi") motion to dismiss for lack of personal jurisdiction pursuant to CPLR 3211(a)(8). Plaintiffs oppose the motion, contending that Fabi is at home in New York and has engaged in sufficient business transactions and purposeful conduct directed toward New York to confer general and specific jurisdiction under CPLR 301 and 302.

Having reviewed the submissions of the parties, specifically New York State Courts Electronic Filing ("NYSCEF") Document Numbers 141 — 145 and 238 — 308, which include the deposition testimony of corporate representatives, distributor agreements, shipping records, and relevant precedent, and having heard oral arguments on September 15, 2025, the Court denies the motion for the following reasons.

The facts underlying this matter are largely undisputed. Fabi is organized outside of New York, with its principal operations located in West Virginia. It is not incorporated in New York and has no registered office, employees, or bank accounts in this State. Nevertheless, the record reflects that Fabi is part of a global enterprise producing talc for use in cosmetics, pharmaceuticals, and industrial applications.

For many years, IMI Fabi (Diana) LLC ("Diana") operated a talc facility in Natural Bridge (Diana), New York. The Diana plant produced cosmetic and industrial grade talc beginning in the late 1990s. In 2001, Diana entered into an exclusive Distributor Agreement with Cosmetic Specialties, Inc. ("CSI"), a New Jersey distributor, appointing CSI as the primary distributor of Fabi's cosmetic talc products in the United States and prohibiting it from handling competing talc lines (NYSCEF Doc No 260). In 2020, corporate restructuring formally merged the Diana entity into Fabi (NYSCEF Doc No 247).

The evidentiary record includes bills of lading and invoices showing shipments of Fabi talc directly into New York ports (NYSCEF Doc No 290) and deliveries to Rouses Point, New York between 2015 and 2020 (NYSCEF Doc No 286). Correspondence confirms Estee Lauder in New York as a direct customer of Fabi talc (NYSCEF Doc No 287), while Chanel's raw material specifications identified talc manufactured at the Diana facility (NYSCEF Doc No 277). Avon similarly approved talc formulations incorporating Fabi material (NYSCEF Doc No 288).

Plaintiffs allege exposure in New York to cosmetics and consumer products containing Fabi talc and bring this action seeking to hold the company answerable in this forum.

CPLR 301, subjects a corporation to general jurisdiction only where it is "at home," namely in its state of incorporation or principal place of business, absent exceptional circumstances (Daimler AG v Bauman, 571 US 117, 137 [2014]; Aybar v Aybar, 37 NY3d 274, 289 [2021]). Defendant urges that it is not "at home" in New York under Daimler and Aybar, in which both the United States Supreme Court and the New York Court of Appeals reiterated that general jurisdiction over a corporate defendant lies only in its state of incorporation or principal place of business, absent exceptional circumstances. This Court agrees. Fabi is neither incorporated nor headquartered in New York. The mere fact that Fabi operated a cosmetic talc facility in Diana, New York, from 1997 through 2004 does not render the company "essentially at home" in this State in 2025, particularly given the Supreme Court's strict limitations in Daimler. Plaintiffs, therefore, cannot establish general jurisdiction under CPLR 301.

The question turns to whether Plaintiffs may establish specific jurisdiction pursuant to CPLR 302. Plaintiffs argue that Fabi "transacted business" in New York within the meaning of CPLR 302(a)(1) and committed tortious acts outside the State causing injury within New York under CPLR 302(a)(3). The record supports both theories.

In Volkswagenwerk Aktiengesellschaft v Beech Aircraft Corp., (751 F2d 117 [2d Cir1984]), the Second Circuit explained that jurisdiction over a foreign entity may be exercised if its in-state affiliate is so dominated and controlled that it is a "mere department" of the foreign entity. Courts consider four factors: (1) common ownership, (2) financial dependency, (3) interference with personnel and disregard of corporate formalities, and (4) control of marketing and operations. The ultimate inquiry is whether "the local corporation's existence is simply a formality," such that it is fair to attribute its New York contacts to the foreign company (id.).

Both Diana and Fabi are (or were) part of the IMI Fabi group of entities. The sustainability report (NYSCEF Doc No 298) describes IMI Fabi as a unified multinational enterprise. Both entities shared common ownership within the IMI Fabi multinational group. The record shows substantial overlap in executive leadership, with Corrado Fabi and Scott Baker having both testified as corporate representatives for "IMI Fabi LLC, IMI Fabi (Diana) LLC, and IMI Fabi USA Inc.," confirming overlapping management (NYSCEF Doc No 254, 280, 306). Financial records and distributor agreements demonstrate that Diana did not operate independently but as a U.S. production arm within the Fabi supply chain. Marketing and [*2]distribution were not locally controlled. The distributor agreement (NYSCEF Doc No 260) tied Diana's cosmetic talc production to CSI's exclusive national distribution network, ensuring that sales strategy and market penetration were directed by Fabi as a whole.

Applying the Volkswagenwerk framework, there is substantial evidence that Diana was a "mere department" of Fabi. The entities had common ownership, shared officers and representatives, were financially interdependent, and operated under coordinated marketing and distribution strategies. Although Diana ceased to exist as a separate entity after the 2020 merger, its prior activities in New York were undertaken on behalf of the same unified enterprise. Accordingly, the Court concludes that Fabi's New York contacts, including the operation of the Diana facility and contracts with CSI, are attributable to Fabi for purposes of specific jurisdiction (see Volkswagenwerk, 751 F2d at 120—22; see also Jazini v. Nissan Motor Co., 148 F3d 181 [2d Cir 1998][distinguishing cases but reaffirming the "mere department" test]).

This Court emphasizes that attribution of Diana's contacts to Fabi is confined to the analysis under CPLR 302 and does not expand the limited reach of CPLR 301 after Daimler and Aybar.

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2025 NY Slip Op 51496(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/ludwig-v-imi-fabi-llc-nysupctniagra-2025.